The CDM in itself does not directly reduce global GHG emissions but helps to achieve a given emission reduction target at a lower cost. Our views in this submission are presented in light of the risks the CDM poses to environmental integrity if CERs are issued as a result of wrong figures or statements given in the PDD and assessed documents and address the threshold of the application of materiality.
This submission highlights key safeguards that must be included in the appeal procedure in order to promote transparency, accountability, and consistency in the CDM project approval process, improve the efficacy of the CDM as a tool for reducing greenhouse gas emissions, and allow for more meaningful public input into the EB’s decision-making – something that is woefully lacking under the current procedures.
This request aims to address a number of methodological issues in the current version of AM0001. The request proposes to address the following four issues: Adequacy of the HFC-23/HCFC-22 ratio used for emission reduction calculations; Adequacy of the cap on historical HCFC-22 production; Implications of the new agreement under the Montreal Protocol and Lifetime of existing facilities.
The recommendations in this submission focus on the voice of civil society within the CDM process. While there are opportunities for public participation throughout the CDM validation process, these seize to exist once the validation report is submitted to the UNFCCC. If a designated operational entity decides to validate a project activity despite serious concerns by civil society, there are no further opportunities for public input. Hence, there is no official way to challenge a designated operational entity against wrong claims in a validation report or to raise concerns about the project that only appear after the last official opportunity for public input has taken place.
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